Two new schools in the Kingwood area are building up, not out. Hopefully, this trend will, in a small way, reduce the percentage of impervious cover and create room for detention ponds to capture stormwater runoff.
Earlier this week, I photographed Kingwood Middle School and West Fork High School construction. As of mid-August, the structural steel work for both is almost complete.
Kingwood Middle School Replacement
The site looks crowded now, but when the new three story facility is complete, athletic fields and a giant detention pond will replace the old facility.
Looking west toward Woodland Hills Drive. KMS Construction as of mid-August 2021Looking east from over Woodland Hills This view looking north makes it easy to compare the height of the old and new buildings.The structural steel work has reached its eastern limit.
To see the progress, compare the pictures above to those in previous posts.
Several weeks ago, New Caney ISD named its third high school the West Fork High School. It too will be a three story structure, and is going up between Sorters-McClellan Road and US59 south of Kingwood Drive.
Looking NNE over the new campus toward Kingwood Medical Center. Insperity, and Kingwood Drive. US59 in upper right.Wider shot looking NNW toward the West Fork shows a large detention pond in the foreground is now grassed in. However, note sediment entering the pond through storm sewers that drain the site.Looking SW toward Sorters-McClellan Road and West Fork. River is mostly hidden behind trees. For reference, note Costco in upper left.
Note the football field and track taking shape in the left middle of the frame and the field house still going up next to it.
To see the progress, compare the pictures in these posts:
New Caney ISD expects to complete construction by the summer of 2022.
Posted by Bob Rehak on 8/20/2021
1452 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/20210819-DJI_0387-2.jpg?fit=1200%2C799&ssl=17991200adminadmin2021-08-20 12:34:032021-08-20 12:34:08Education Going Higher; Construction Updates on Two New Schools
For those wishing to submit comments about sand-mining Best Management Practices (BMPs), but who may feel daunted by the complexity, I’ve compiled a list. If you use a computer-based email application, you should be able to submit it with one click.
It should address and title an email, then automatically insert the recommended text shown below. Don’t forget to insert your own contact information at the end of the email, before hitting the send button.
I have not tested the automated link with all email apps, browsers and platforms. So if you run into problems, just cut and paste the text between the separators below. Again, don’t forget to add your contact information.
Please share this with all your friends, family and neighbors. Ask them to submit the comments and share it, too.
Deadline: 8/19/21.
Dear TCEQ,
After reviewing the Draft Proposed BMPs for Sand Mining in the San Jacinto River Basin, I have several comments that I would like you to consider.
Geographic area should include “all tributaries draining into Lake Houston,” not a limited subset.
Include provision that steps up enforcement. Operators already routinely violate too many of these BMPs.
Introduction: Put the need for BMPs in perspective by including a sentence or two that talks about the $222 million spent by Federal, State, and Local governments to dredge the San Jacinto.
Introduction: Add this thought. “The presence of the Lake Conroe dam can lull operators on the West Fork into a false sense of security. During Harvey, Lake Conroe released 79,000 CFS. All by itself, that would have qualified as the ninth largest flood in West Fork history, even if not a drop of rain had fallen anywhere else in the watershed. Such high rates of conveyance lead to high rates of erosion and sediment transport that require operators to exercise extreme caution in this environment and closely follow the BMPs below.”
Introduction, include a sentence to this effect. “When deviating from standard BMPs, the operator must file documentation with the TCEQ which will be posted for public inspection and obtain written approval from the TCEQ.”
Introduction: In the bullet point after “Geographic Location,” replace “hydrogeology” with “Surface and groundwater hydrology.”
Introduction: After the sentence which ends with “…implemented by the sand mining operators,” Include the following. “All BMPs must be submitted to the Executive Director (ED) of the program for review and approval.”
2.1: Replace “next anticipated storm” with “must repair or replace controls immediately when damage is noted during weekly inspections.”
2.1.1: Define the 100-foot buffer zone as “…measured from the stream bank to the closest disturbed area…”
2.1.1: After “and 35 feet for intermittent streams” insert the following: “Wider buffer zones might be necessary where riverbank erosion rates are high.”
2.2: Change Site operators must “inspect disturbed areas” to “inspect and document disturbed areas.”
2.2: After “…All structural controls must be in compliance with local rules and permitting requirements,” add: “including special restrictions for construction in a FEMA-defined floodway.”
2.2: Require that operators inspect all structural controls “once every seven (7) calendar days.”
2.2.5: Specify that “operators must measure and document the depth of sediment basins at least once a year, as well as before and after major floods.”
2.2.5: Add: “Special consideration must be given to stability of the outer dike (or levee) separating the pits from the vegetated buffer zone adjacent to the river. Lateral erosion of the river can result in breaching of the dike and potentially rerouting the river through the pit area (pit capture).”
2.2.5: Specify what operators must do “prior to discharge” to have a “permitted” discharge.”
2.2.6: In the sentence that ends with “…will not erode the receiving stream,” add “…or adjacent properties.”
2.2.10: Detention ponds big enough to hold an inch of rain seem wholly inadequate in an area where Atlas-14 specifies 16.9 inches for a 100-year event. Harris County Flood Control District recommends minimum detention volumes for developments at .65 acre feet per acre. That’s about 8 inches of rainfall. Please modify required depth.
3.1: Specify that TCEQ must approve the mine plan.
3.1: Mention that building mines in floodways requires extreme precautions for virtually every facet of mining. (This section currently makes no mention of floodways, yet virtually all San Jacinto mines are at least partially built in floodways.)
3.1: Replace the sentence that starts with “An evaluation of…” with “The susceptibility for erosion of on-site soils and lateral erosion rates of adjacent rivers must also be known in the pre-planning stages. If parts of the proposed mine are located in a FEMA-defined floodway, hydrologic and hydraulic analyses performed in accordance with standard engineering practice must demonstrate that the proposed encroachment will not result in any increase in flood levels or erosion of upstream, downstream, or adjacent properties.”
3.2.1: After the sentence that ends with “…other than TCEQ hold jurisdiction,” replace the next sentence with “Additional erosion controls or increased buffer widths may be needed where river erosion rates are high, receiving streams are listed in the Clean Water Act (CWA) 303(d), or critical facilities (e.g. bridges, pipeline or utility corridors) are adjacent to the proposed operation.”
3.2.1: Complete the sentence that starts with “Understanding site drainage can be obtained by using…” with “existing LiDAR and aerial photo images.” Delete the part about USGS Topographic maps which show a series of contour lines. Then modify the next sentence in that paragraph to read, “These images (combined with lower resolution USGS topographic maps) can be used to determine slope of the ground surface through the site to identify drainage patterns.”
3.2.2: After the sentence that ends with “…water supply wells are located nearby,” add this sentence: “If present, waste management units must be located a minimum horizontal distance from adjacent water wells, in accordance with 16 Texas Administrative Code Chapter 76.”
3.3: Say “Topsoil material MUST be temporarily stockpiled for future use in post-mining activities.”
3.3: Add this thought. “Stockpiles may not be located in floodways.”
3.3.2: After, “…diverting upslope water around a planned area for disturbance is also good practice,” add “however, care must be taken to not have the diverted water result in increased downslope flooding.”
3.3.3: Change the sentence that starts with “Stockpile protection is most effective when…”, so that it reads, “Stockpile protection is most effective when stockpiles are not located on the FEMA-defined floodway, are located away from concentrated flows of storm water, drainage courses, and inlets, and when are properly protected with perimeter sediment barriers and covered.”
3.3.3: After the sentence that ends with “…geoscientists certifying BMPs at the site,” add another sentence that reads, “Additional buffer width or structures may be required where critical structures such as pipeline or utility corridors are located.”
4.1: Add: “Operators should not dredge a vertical wall at the edge of buffer zones. This can lead to cave ins at the edges that decrease the width of the buffer zones. It may also not leave enough room to taper slopes enough to plant vegetation in the post-mining phase.”
4.5: Add “All fuel storage tanks must be located outside of floodways.”
4.5: Add “New floodplain and floodway maps for the San Jacinto region should be released sometime in 2022 or 2023. Floodways are expected to expand by approximately 50%. Take this into account when planning placement of storage tanks.”
4.5: Add “Remove all fuel storage equipment and tanks before abandoning a mine.”
4.6: Add new section that includes this thought.
5: Change the first sentence in the introduction to say, “The Post-Mining Phase stabilization plan must be approved by TCEQ, subject to input from the landowner and downstream property owners.”
5.1: Change “may” to “must” in the second sentence and delete several subsequent words so that it reads, “The following guidelines MUST be used to meet site stabilization objectives.”
6: Replace the entire introduction with the following: “Prior to operations beginning at a sand mining facility site or portion(s) of the site, an initial stabilization report must be submitted to the executive director for review and approval at (Address). The Initial Stabilization Report must, at a minimum, include and demonstrate that the items described below in section 6.1 Report Requirements will be addressed. This initial report will be updated annually to reflect current mobilization and reclamation areas.”
6.1: Add: “After completion of mining, remove all vehicles and debris that could be swept downstream in a flood.”
6.1: Under Structural Controls, after the sentence that ends with “…manage remaining onsite drainage,” add another sentence. “This includes making sure the outer dike (or levee) that separates the abandoned pits from the adjacent river is not breached due to lateral erosion of the river.”
6.1: Under High Walls, after “The permittee shall demonstrate that all remaining highwalls are stable and safe,” add the following. “This may mean leaving enough buffer between adjoining properties to taper slopes to a gradient that will allow the planing of vegetative controls that prevent erosion.”
6.1: Add: “Conservation easements on buffer areas, placed before mining, could be utilized to ensure community protection. Conservation easements placed post-reclamation would ensure that site ecology would be monitored, and restoration activities completed. An accredited land trust involved as a conservation partner would provide third-party documentation of adherence to the ecological practices outlined in these guidelines and provide community oversight that is currently missing.”
Glossary: Add “Floodway (Regulatory Floodway) – the channel of a river or other watercourse and the adjacent land areas that must be reserved in order to discharge the base flood without cumulatively increasing the water surface elevation more than a designated height.”
If you would like to provide your own public comments, email Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” by the close of business tomorrow.
This company lost property (red circles) when a sand mine left highwalls around it that collapsed into the pit.Photograph of same areas taken on 8/17/2021.
Each of the recommendations above has a story behind it like these pictures tell. Please help by submitting public comments.
Posted by Bob Rehak on 8/19/2021
1451 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/20210817-DJI_0356.jpg?fit=1200%2C799&ssl=17991200adminadmin2021-08-18 20:03:342021-08-18 22:19:10One-Click Submittal for Suggested Public Comments on Proposed Sand-Mining BMPs
Below is this week’s digest of flood-related news affecting the Lake Houston Area.
San Jacinto Regional Flood Planning Group
Save the date. The San Jacinto Regional Flood Planning Group (Region 6) will hold it’s next public meeting on Tuesday, August 31, 2021, from 6:30 to 7:30 PM. You must register here to receive meeting access information and an online calendar invitation.
The first regional flood plans will be due in January 2023, and the first state flood plan will be due to the Texas Legislature by September 1, 2024.
The upper watershed has a new representative to this group: Neil Gaynor from The Woodlands. Mr. Gaynor has a PhD in Geology and will serve the area well.
Liberty County Drainage District
According to the Bluebonnet News, on Tuesday August 10, Liberty County commissioners approved the creation of a drainage district to serve the entire county. County Judge Jay Knight is quoted as saying, “The goal is to mitigate flooding and enhance drainage in the entire county.” Commissioners appointed a temporary board to draw up by-laws. But the District must still be approved by voters, because this would be a taxing district.
“I don’t want Liberty County to be in the same situation as Harris County is in now with its drainage problems,” said Knight. “Now is the time for Liberty County while drainage improvements can be done cheaper and while land acquisition for those plans is much easier. It will be much more expensive if we wait….This gives us another way to make developers behave. I just wish it had been in place 20 years ago.”
The 34-year veteran of the department served many different judges and commissioners. According to one engineer I talked to, he had the toughest engineering job in the county, perhaps even tougher than Poppe’s. But the silence from the media on his resignation speaks volumes.
The Engineering Department works hand in hand with the Flood Control District on many drainage projects, especially those that relate to roads, streets, highways and subdivisions. The Engineering Department is also home of the Infrastructure Resilience Team which works with the Community Flood Resilience Task Force.
Blount has agreed to stay until the Judge and Commissioners agree on a replacement…as long as that can be done before October 1.
From April though July, the Lake Conroe Association filed approximately 2,800 pages of legal briefs in the case.
The case places much emphasis on drought.
Drought Monitor
The Texas Water Development Board posts a weekly drought monitor. Only problem for the Lake Conroe Association is, there isn’t any within a thousand miles. The pocket near El Paso was in drought, but they just had their wettest June/July in 127 years.
USGS data showing the average monthly levels of Lake Conroe for the 18 years before the seasonal lake lowering started. Note: the averages for August and September.
When I came across those figures, I realized that the seasonal lake lowering plan was just designed as insurance in case Mother Nature didn’t do her job in a particular year.
Shhhh. Don’t anyone tell the judge in the LCA lawsuit about Mother Nature’s “wasteful, ineffective, and deceitful program.”
Meanwhile, Lake Houston is slightly above its normal level.
Source: Coastal Water Authority via USGS.
Wayne Dolcefino Takes on MoCo
One of the world’s great investigative journalists, Wayne Dolcefino, has set his sights on Montgomery County now. A subdivision there named Carriage Hills is fighting another subdivision going in next to it. The new subdivision evidently started building streets before the plats were approved. It also failed to take its drainage to the river, so the drainage is spilling onto properties in Carriage Hills.
Photo taken May 26, 2021 of new development next to Carriage Hills on left. Looking South. Note substantial erosionalready.Also taken May 26, 2021 looking South. Note how drainage channel stops short of river. Carriage Hills is to left in heavily wooded area.
Neither the MoCo engineer, nor LJA, which does contract work for the MoCo engineer, seem overly excited about the oversight.
LJA is also reportedly working with TxDoT to build another bridge across the West Fork that will go through several Carriage Hills properties. This has the property owners upset because other routes were available that would not affect their properties.
See Dolcefino’s latest, the “Road to Ruin,” on YouTube.
Dolcefino Carriage Hills Video
TCEQ Best Management Practices for Sand Mines
TCEQ has proposed Best Management Practices for Sand Mines in the San Jacinto River Basin.
If you haven’t yet submitted your public comments, they’re due tomorrow. My last post on this subject includes links to a series of previous posts that describe gaps and areas for improvement.
If you want to help reduce future buildups of sediment in the San Jacinto, please consider sending your thoughts to Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
Later today, I hope to post a summary of concerns that you could forward with one click.
Posted by Bob Rehak on 8/18/2021
1450 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/20210526-RJR_7787.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-08-17 23:17:022021-08-18 12:03:47Weekly Digest of Lake Houston Area Flood-Related News
This is the eighth in a series about Best Management Practices (BMPs) proposed by the Texas Commission on Environmental Quality (TCEQ) for sand mines in the San Jacinto watershed. This post will focus on the Final Stabilization Report that operators should file after mines cease operation.
As we saw yesterday, operators abandon many mines with little thought to stabilization, cleanup, or reclamation. When that happens, mines become a blight on communities and the environment.
Below is the text of proposed BMPs for the Final Stabilization Report. I will provide my comments at the end. Here is a link to the complete text of all BMPs proposed by the TCEQ.
Final Stabilization Report
BMPs within the final stabilization report show what the TCEQ values. One made me scratch my head and sigh “Huh?” Others represent glaring omissions. Below, see the proposed text.
6 Final Stabilization Report
Prior to operations terminating at a sand mining facility site or portion(s) of the site, a final stabilization report must be submitted to the executive director for review and approval at the following address:
Texas Commission on Environmental Quality Stormwater Team Leader (MC-148)
P.O. Box 13087
Austin, Texas 78711-3087
The Final Stabilization Report must, at a minimum, include and demonstrate that the items described below in section 6.1 Report Requirements have been addressed.
6.1 Report Requirements
Vegetative Cover:
The operator shall establish perennial vegetative cover in all areas except where ponds, highwalls, permanent structures, or paved areas exist.
Perennial vegetative cover must be uniform (i.e. evenly distributed with no large bare areas) and have a density of at least 70 percent of the native background vegetative cover for the area.
Vehicle and Equipment Storage and Maintenance Areas:
The operator shall remove fluids and batteries from, and thoroughly clean all vehicles and equipment remaining on-site.
All fuel and chemicals must be removed from maintenance areas. Maintenance areas must be thoroughly cleaned and cleared. If maintenance areas are unpaved, these areas must have vegetative cover established.
Structural Controls:
All temporary structural controls must be removed from the site. Remaining permanent structural controls must be adequate to manage remaining on-site drainage.
Other:
Highwalls: The permittee shall demonstrate that all remaining highwalls are stable and safe.
Waste: All waste must be removed from the site and disposed in accordance with applicable TCEQ rules.
Landowner Agreement: If applicable, a copy of all existing agreements with landowners regarding stabilization of the site must be included.
Certification: The Final Stabilization Report must be signed and certified by a Texas licensed professional engineer or a Texas licensed professional geoscientist.
Comments
I have several comments on these.
The first has to do with vehicles and equipment “remaining” onsite. The BMP only requires that the operator must “thoroughly clean all vehicles and equipment remaining on site”! Really? Why not require removal?
This BMP lets operators turn old mines (and our river system) into junk yards. It’s a recipe for urban decay. Rivers flood periodically and will inundate the old equipment and abandoned vehicles. Simply cleaning it before it floods and rusts is a joke.
If operators don’t want the equipment and vehicles they should sell them to another operator or for scrap, not just clean them. Don’t turn them into a blight on the landscape or communities.
Sand mining equipment abandoned for years between downtown Humble and the West Fork.One operator’s idea of cleaning an excavator before abandoning it. This pit is now open to the river through erosion.
Second, the Final Stabilization report BMPs make no mention of removing debris.
Give me a home…where the deer and the antelope roam!Abandoned West Fork Mine.
Third, nor do they mention removing old buildings which could attract squatters and drug users.
Abandoned East Fork Mine with rusting buildings still on site.
Fourth, they make no mention of ensuring that outer dikes (or levees) separating abandoned pits from adjacent rivers are not breached due to lateral erosion of the river.
Abandoned mine after Harvey on right, West Fork on left.Same area today. Lateral erosion breached dike allowing sediment to escape.
Finally, as with the BMPs in previously covered sections, enforcement is an issue here, too.
So where’s the vegetative cover?The high wall of this pit has partially collapsed endangering properties around it and people standing near it. The wall was not properly stabilized.
Public Comments Due by 7/19/21
Please submit your thoughts on the Final Stabilization Report and other BMPs to the TCEQ. Email Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
Posted by Bob Rehak on 8/17/2021
1449 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/20210101-RJR_4113.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-08-17 13:14:112021-08-17 13:20:34BMPs for Final Stabilization Report Omit Crucial Elements
This is the seventh in a series about Best Management Practices (BMPs) proposed by the Texas Commission on Environmental Quality (TCEQ) for sand mines in the San Jacinto watershed. This post will focus on post-mining activities – what should happen after the mine ceases operations.
As with previous posts, I will summarize the proposed BMPs and provide my comments at the end. Here is a link to the exact text of the BMPs proposed by the TCEQ.
Proposed Post-Mining BMPs
5 Post-Mining Phase
Post-Mining stabilization may depend on an agreement with a landowner; sometimes mines lease land, but often they own it.
Activities may involve stabilization of inactive pits or borrow areas with herbaceous perennial plants.
Stabilizing the soil helps prevent wind and water erosion from causing damage. It also improves the site’s aesthetic appeal and its ability to support wildlife.
This practice applies to sand borrow areas where soil has been replaced to approximate original conditions as well as where the soil profile has been removed.
5.1 Site Stabilization
Evaluate soil characteristics to help stabilize soil and prevent erosion. The following guidelines will help meet site-stabilization objectives.
Slope stability: Cut-and-fill slopes must not exceed 2:1 to provide stability. Gentler slopes (3:1) support seeding efforts better. Avoid long slopes to help prevent erosion, and allow access for seeding, mulching, and maintenance.
Diversions: Construct diversions at tops of slopes to divert runoff away from the slope banks to a stable outlet.
Chutes: Construct aggregate lined chutes or equivalent to conduct concentrated flow of water to stable outlets.
Soil Conservation: Reclaim abandoned roads by reshaping, recontouring, and resurfacing with topsoil. Seed them to grow vegetation. Remove structures such as bridges, culverts, cattle guards, and signs. Remove remaining sand stockpiles to eliminate potential for offsite discharge during stormwater flows.
Operators must practice good soil conservation and seed bare ground during the post- mining phase to aid in minimizing and/or reducing the potential for stormwater to wash sediment loads from unvegetated areas into nearby waterways. Natural regeneration takes time and during that process much sediment could be washed away as sheet, rill or gully erosion over that period.
If active revegetation is selected, seeds that are conducive to the season and type of soil present must be used to vegetate any bare areas. Mulching (using hay or erosion control blankets, for example) also aids in seed germination and helps prevent or minimize sheet, rill and gully erosion. The NRCS office can help in the proper selection of the types of seeds and nutrients required for proper vegetative growth.
5.2 Debris and Vegetative Waste Removal
Typical debris from sand mining usually involves trees and shrubs generated from the land clearing stage of the mining process. These trees and shrubs may be placed back into the mined portion of the property and covered with overburden material.
This debris can also be stockpiled and burned if the operator complies with the outdoor burning rule in 30 TAC §§111.201 – 111.202. For more information about complying with the outdoor burning rule, operators must refer to the TCEQ guidance document Outdoor Burning in Texas (RG-049),
All waste disposal for the site must be done in accordance with TCEQ Municipal Solid Waste Rules found in 30 TAC Chapters 330, 328, and 332.
5.3 Property Grading
After completion of mining activities, operators grade the property. This minimizes non-point source stormwater pollution (i.e., sediment fines) from impacting potential pathways such as streams, creeks, tributaries, lakes, etc.
Abandoned sand mine in Plum Grove left in shambles. Not replanted. Stockpiles not removed. Equipment abandoned onsite.Same mine after heavy rains in early May. East Fork captured pit, swept through mine, and carried sediment downstream.More breaches in same mineand more sediment being swept downstream.
Rehak’s Concerns about Post-Mining BMPs
Again, these post-mining BMPs are good as far as they go. However, there are gaping omissions.
One has to do with enforcement. Another has to do with abandoned equipment. While I’ve seen one sand mine on the West Fork that took great care to convert the site to suitable and aesthetic post-mining use, typically miners just walk away from the property and leave it in shambles.
One of the biggest concerns not addressed here: abandoned equipment that leaks oil, creates eyesores, and poses safety hazards.
Abandoned mine on North Houston Avenue in Humble, just blocks from downtown.More equipment at same mine.Submerged excavator at abandoned West Fork MineAbandoned equipment at abandoned East Fork mine. Has since been removed after complaint to TCEQ.Abandoned dredge at same mine. Still there last time I looked in May.Near vertical slopes at this abandoned mine will probably never revegetate until erosion grinds them down.They also pose safety hazards for children playing nearby. This particular mine is between a paint-ball facility and a driving range.
Another post-mining issue is that reclamation depends on the good will of the miner. When all the profit has left the site, what incentive does he have to spend money to reclaim the land.
Without performance bonds to ensure post-mining reclamation, I fear that most miners will leave their property like they have in these pictures. Performance bonds are a common practice in the construction industry; they ensure satisfactory completion of a project.
Without such bonds, there can be virtually no enforcement of these post-mining BMPs. What leverage does the TCEQ have at that point? An operator could just declare bankruptcy, walk away from his obligations, and re-incorporate under a different name. The owner of one of the abandoned mines shown above has his name associated with dozens of defunct organizations.
Public Comments Due by August 19
Please submit your thoughts on Post-Mining and other BMPs to the TCEQ. Email Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
Posted by Bob Rehak on 8/16/2021
1448 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/20180617-SandMineHumble_27.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-08-16 15:05:172021-08-16 15:12:37TCEQ Proposes BMPs for Post-Mining Phase, But Is There Any Incentive to Comply at That Point?
At the present time, Jeff Lindner, Harris County Meteorologist, expects no direct impacts to the upper Texas Coast, with the possible exception of some high tides and large swells.
Greater impacts with squalls and higher seas appear more likely along the lower Texas Coast into the weekend.
As always with tropical systems, check forecasts frequently for changes. Remember, forecasts for this storm have shifted direction a whopping 90 degrees in less than a day. Yesterday afternoon, NHC forecast the storm to head toward the Florida panhandle; last night it was headed toward Texas. Today, they show it heading toward the Mexican mainland.
Cone of uncertainty for Grace. Remember: the storm has an equal chance of making landfall anywhere within the cone.
Strong trade winds will continue to push the storm west.
Air Force Reserve and NOAA Hurricane Hunters were both able to locate a center for Grace–and measured several possible areas of tropical-storm-force winds.
High pressure over the western Atlantic is forecast to slide westward over the southeastern United States during the next several days, which should keep Grace on a westward to west- northwestward trajectory for the entire 5-day forecast period.
Forecast Maps
Grace is the lower, elongated storm. The purple area is Fred. And the red area in the Atlantic is a third is tropical depression 8.Tropical-storm-force winds could hit the Mexican mainland on Friday.
All available models closely agree on the new track.
Models are starting to show consensus on Grace’s track.
Intensity Forecast
Grace’s intensity forecast remains complicated by interaction with land and the possibility of some westerly shear during the forecast period. However, the southern shift in the forecast track takes the center of Grace over very warm 30 degrees Celsius waters in the northwestern Caribbean Sea. Therefore, Lindner expects gradual strengthening.
Once the system reaches the Gulf of Mexico, shear should decrease, says Lindner, and conditions will support additional strengthening. Many models bring Grace to hurricane intensity by the end of the forecast period.
Favorable upper level and sea surface conditions along the path of Grace over the southern Gulf support some of the stronger solutions and tropical systems in this area of the Gulf tend to have a history of quick development. NHC is currently indicating Grace nearing the Mexican coast as a tropical storm, but a hurricane is certainly possible.
Posted by Bob Rehak on 8/16/2021 at noon based on information from NHC and HCFCD
1448 Days since Hurricane Harvey
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/145633_5day_cone_no_line_and_wind.png?fit=897%2C736&ssl=1736897adminadmin2021-08-16 11:49:482021-08-16 11:55:51Grace Now Expected to Track Farther South, Turn Into Tropical Storm Tuesday
According to the 8PM EDT update from from the National Hurricane Center on Sunday, 8/15/2021, Tropical Depression Grace is now expected to track more westerly toward the Texas Coast. Earlier, forecasters predicted Grace would follow Fred’s path toward the Florida Panhandle. However, even if Grace remains on the new track, it would not reach the Texas Coast until Friday night.
Topical storm force winds could arrive almost a day earlier.
Watches and Warnings Already Up for Islands
NHC advises that there is a risk of flash, urban and small stream flooding for islands in the Caribbean.
Forecast Uncertainty Higher than Usual
NHC also advises that forecast uncertainty remains much higher than usual for Grace.
Present movement is directly west (270 degrees) at 15 mph with sustained winds of 35 mph.
Forecaster predict the storm will dump 3-6 inches over Puerto Rico and the Virgin Islands. Four to eight inches could fall on the Dominican Republic and Haiti.
Possible Threat to Texas Later This Week
If Grace survives land interaction, it could threaten Texas later this week. It’s important to remember that the storm has an equal chance of hitting any area the cone. The cone does not represent the expected width of the storm and dangerous winds could extend well outside the cone.
This is the sixth in a series on Sand Mining Best Management Practices (BMPs) proposed by the Texas Commission on Environmental Quality (TCEQ). BMPs help reduce erosion and prevent pollution, but these don’t address some important issues.
Strengthening them could reduce both the magnitude and toxicity of future floods. By reducing the amount of excess sediment that enters the river, we can help reduce blockages that contribute to flooding. And by better managing fuels, we can help reduce the toxicity of stormwater runoff.
Public comments are due by August 19, 2021.
Equipment at West Fork mine separating sand and gravel.
This post will focus on the actual mining phase. For brevity, I will summarize the BMPs. But here is a link to the exact proposed text. I will also provide suggestions for improvement at the end of this post for those committed individuals still with me.
Large parts of this section describe the mining process. Some have no BMPs. I have summarized the process and tried to condense the BMPs for readability.
As we saw in the post about setbacks, simply having the setback requirement is no guarantee operators will observe it. Likewise with some of these BMPs.
I never really thought about fuel storage at a sand mine until I read these BMPs. Then I reviewed by pictures and found that few mines would comply with these proposed rules.
4.1 Dredging Activities
After stripping away overburden, dredging begins. Suction and pumping send sand and other materials to a wash plant where they are separated using a sizing screen. Water generated during the pumping process can flow back into the pit. Sand is separated from gravel and stockpiled or sent to the pit via a sand flume. Sized aggregate is stockpiled onsite until sale.
4.2 Aggregate Wash Plant Area (Wet Processing)
Process wastewater results from the production, clean-up, or use of any raw material, intermediate product, finished product, byproduct, or waste product. Treatment of wastewater before discharge to alter its characteristics is often required to achieve compliance. Examples of treatment include pH adjustment and removal of solids through either physical or chemical means prior to discharge to surface water.
BMPs required during this portion of the mining process include proper berming and/or ditching of pump water from the dredge to the wash plant and back into the open pit.
Pump water flows back into the pit to avoid unpermitted process water from escaping.
Runoff from the stockpiles must be routed to the open pit. Rainfall runoff from stockpiles must also go to the pit.
Other BMPs include silt fencing, berms, and vegetated buffers to ensure runoff from stockpiles is controlled.
4.3 Aggregate Processing Plant Area (Dry Processing)
Some sand used for fill, bedding, etc. does not require processing, but most does. Processing for specific markets involves the use of different combinations of washers, screens, and classifiers to segregate particle sizes.
After transport to the processing plant, the wet sand (raw feed) is transported to fixed or vibrating scalping screens that separate particle sizes. Oversize material may be directed to a crusher for size reduction to produce manufactured sand. Following crushing, material returns to the screening operation for additional sizing.
Alternatively, oversize material (greater than two inches) may be used for erosion control, reclamation, or other uses.
During screening, water sprayed onto material removes clays and other deleterious material.
After classification, sand is dewatered, then conveyed to storage bins or stockpiles.
4.4 Maintenance Area(s)
Controlling contamination of stormwater is critical. Stormwater quickly picks up pollutants from improperly stored materials or spills.
Train employees to cover toxic materials, channel stormwater, and perform preventative maintenance to reduce pollutant-laden stormwater.
A Spill Prevention Control & Countermeasures (SPCC) Plan must be in place to implement spill prevention and response. Ongoing inspection assures that site management is having the desired effect.
Locate fuel/oil storage/handling facilities away from the main sediment and wash-water retention facility.
Equip all such facilities with approved containment, monitoring, and collection systems.
No containment system here. No runoff provisions. Note rusting 55 gallon drum.
Store fuel above ground.
Route runoff from adjacent surfaces to a retention pond that can be cleaned after a spill.
4.5 Petroleum Product Storage and Handling Area
1. Regulatory Requirements
Operators must comply with all local, state, and federal requirements for petroleum storage tanks.
TCEQ requires registration of petroleum storage tanks.
Many BMPs address proper storage, handling, and transfer of petroleum products. Some of the more important BMPs include:
Signs must be posted instructing drivers to remain with their vehicles at all times to prevent overfill spillage.
Fuel delivery drivers must be chock wheels or lock brakes prior to offloading fuel, and ensure all hoses are disconnected prior to departure.
All fuel transfer areas must have secondary containment large enough to handle the largest single compartment of any tank truck in the facility. Alternatively, discharged material must be directed to a containment pond through the use of berms and swales.
Use drip pans or buckets at disconnection points of hoses and/or piping to collect drippage of oil.
Inspect all storage tanks once per month for signs of fatigue or failure that could lead to the spillage. Document these inspections. Promptly repair any leaking, corroded, or deteriorated tanks that could discharge oil.
Examine all pollution prevention equipment once per month to ensure it is in good operating condition. Fill out and keep onsite the monthly report.
Build secondary containment structures around all bulk oil and lubricant storage tanks. They must have sufficient capacity to contain any spills caused by rupture of the tank.
No containment structures.
All secondary containment structures must have 110 percent of the capacity of the largest storage tank and must be constructed of material impervious to tank contents.
Fuel stored out in open with no containment structure.
Containment structures must have manually operated gate valves to drain rainwater. Alternatively, keep a portable pump available to drain the containment area. All manually operated valves must be locked closed when not in use.
Inspect accumulated rainwater prior to discharge to ensure that there is no petroleum sheen on it. Water with a sheen must never be discharged. It may be pumped for disposal, allowed to evaporate, or removed by some other appropriate method. TCEQ requires documentation the visual inspection.
Oil Discharge Response and Cleanup
When an oil discharge happens within the plant area, all manpower and equipment available must be utilized to prevent the discharge from reaching a navigable waterway. Stop the discharge. Control its impact to the environment.
Procedure after a discharge:
The first person to notice the discharge must immediately notify the plant superintendent; the superintendent, in turn, must simultaneously implement best management practices to capture the discharge.
Depending on the volume of the spill, the operator is required to notify TCEQ immediately, or at least within 24 hours. Operators must refer to 30 TAC Chapter 327 for complete rules and regulations regarding spills.
If possible, prevent further leakage by plug sources and/or closing valves.
A front-end loader must be immediately available to build a berm or dike with dry sand to absorb the discharge if the secondary containment should fail.
In the event of a discharge on the concrete in the shop or other hard surface, the following procedure must be used:
Absorbents must be used to keep the discharge from leaving the hard surface.
Identify the source of the discharge and fix the leak by whatever means necessary.
Place used absorbent in a drum (labeled with USED ABSORBENT, NON-HAZARDOUS). The drum must have a lid, which is kept on at all times when not in use. The drum must have the first date the used absorbent was placed in the drum. Keep drums under a roofed structure to prevent stormwater contamination.
If any discharged material has left the impervious surface, the media contaminated from the discharge must be properly removed and disposed of in accordance with all applicable local, state, and federal environmental regulations.
If the discharge is too large for plant personnel to contain, employ a contractor.
After the leak is repaired, the discharged product must be recovered from the secondary containment and appropriately managed in accordance with current state and federal regulations. If sand or surface soils are contaminated, dispose of them in accordance with current state and federal regulations.
Rehak’s Take
These BMPs address fuel management more than mining. In my opinion, both sections are good as far as they go. But I would like to see at least some BMPs added based on observations of actual practices.
Under dredging:
Operators should not dredge a vertical wall at the edge of buffer zones. This can lead to cave ins at the edges that decrease the width of the buffer zones.
Dredging next to buffer zone can cause cave-ins that reduce buffer’s width, especially when the pond wall is deep and steep.More slope would reduce the chances of buffer collapse.
Under fuel management:
Fuel depots and fuel storage tanks must be located outside of the floodway, on the highest ground possible and as far from rivers as possible. Make sure the location meets Atlas-14 requirements.
Rusting fuel storage tanks in floodway without covers or containment structures. When Atlas 14 maps are released next year, this area will be even further into the floodway.
And two more:
Remove all fuel storage equipment and tanks before abandoning a mine.
Abandoned equipment on East Fork mine has since been removed after a complaint to the TCEQ.
Finally, do not store excavation equipment underwater.
This piece of equipment has been abandoned in this mine for years.
To Submit Public Comments
Please submit your thoughts on Mining and other BMPs to the TCEQ. Email Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
Posted by Bob Rehak on 8/15/2021
1447 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/ImeldaWoodstream_001.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-08-15 17:29:382021-08-15 17:33:26Mining BMPs Could Help Reduce Toxicity of Floodwaters
According to best management practices (BMPs) being proposed by the TCEQ, pre-mining planning is one of the main ways to prevent sediment from leaving a mine.
So much sand piled up in the San Jacinto after Hurricane Harvey that it reduced the conveyance of the river, contributed to flooding, and cost hundreds of millions of dollars to remove.
I consider good sand mining operations so important to the reduction of future flooding that I am publishing a series of articles on these proposed BMPs. This is the fifth. The first provided an overview. Then, I discussed:
This post will discuss BMPs for pre-mining and provide a list of suggestions for public comment at the end.
Life on the edge. Expansion of a West Fork sand mine right up the edge of the river’s cut bank. That will make this future mine especially susceptible to river migration and pit capture. It is probably not a good idea to mine this close to this part of the river.Bad pre-planning!
Miners must begin by evaluating a site for how mining will take place and what will happen to the mine when it closes. This is typically called a Mine Plan and includes:
Location of processing plant, office, support facilities, roads, product staging areas, and overburden placement.
An evaluation of the soil type(s) in the area planned for mining.
Susceptibility of these soils to erosion must be known when planning. Sands, silts and clays act differently when worked by earthmoving equipment.
3.2 Understanding Site Drainage
It is important to know pre-existing drainage patterns and where concentrated flows want to exit a site. This will determine the selection of structural control BMPs, such as culverts, to minimize adverse impacts.
3.2.1 Surface Water Flow
Identifying the receiving waters (i.e., Lake Houston, the San Jacinto, Spring Creek, Caney Creek, White Oak Creek) is vital before site preparation starts. Operators must determine all appropriate agencies with jurisdiction over the receiving waters. The TCEQ and USEPA Region 6 continuously develop Total Maximum Daily Loads (TMDLs) for water bodies not meeting their designated uses.
Inspection during or after a rainfall event can provide a substantial amount of information regarding how surface water flows.
3.2.2 Ground Water Conditions
Understand that mining of a potable aquifer can negatively affect the yield of a potable well.
The following BMPs will help guide a ground water preservation effort:
When a new sand and gravel operation is being considered, operators must first check the Texas Water Development Board water well reports data and the TCEQ water well report viewer to determine if registered public and private drinking water supply wells are located nearby.
Perform a visual check for possible unregistered private wells or abandoned wells in the immediate vicinity of the new sand and gravel pit. If an unregistered private well or abandoned well is discovered, operators must refer to TCEQ’s Regulatory Guidance Landowner’s Guide to Plugging Abandoned Water Wells (RG-347) for more information on the necessary actions which must be taken.
3.3 Site Preparation
Only after surface water drainage and ground water conditions are thoroughly understood may site preparation be initiated.
Once initiated, operators must inspect disturbed areas (cleared, graded, or excavated) of the site at least once every seven (7) calendar days for signs of visible erosion.
3.3.1 Construction of Access and Haul Roads
Roads are a necessary component of any sand and gravel mining operation, especially on large pieces of property. Operators must take care to minimize impacts to the environment when constructing roads.
Roads must be designed to drain at all times by using crowning, graveling, compacting, ditching, and/or culverting
Proper construction and maintenance should minimize erosion by rainfall runoff, dust, and normal vehicle use. Where necessary, road surfaces must be graveled if the base does not already contain sufficient aggregate.
Crowning of Roads
Surfaces must be crowned to minimize erosion of the roadbed.
Graveling and Compacting
Graveling and compacting of road surfaces require less maintenance. It minimizes loose sediment runoff or tracking of sediment onto public roads.
Ditching and Culverting
Ditches and culverts carry runoff alongside or underneath a roadbed. They must be:
Sized for anticipated rainfall events.
Installed at the time of roadway construction
Sloped to prevent silting and allow for maintenance (i.e., digging out sediment buildup).
Kept free of debris and obstructions.
Typically, ditches can be used for routing surface water flow away from adjacent properties offsite.
Silt Fencing
Silt fencing can aid in soil erosion caused by surface runoff from roadways. The bottom must be secured beneath the ground surface to prevent under-washing.
3.3.2 Land Clearing and Grubbing Activities
Land clearing and grubbing involves removing all trees, stumps, roots and other debris from the site. It may also include removal and disposal of old, unwanted structures. Proper disposal will be discussed in a later post.
Disturb only those areas ready for immediate use. Install sediment holding basins before major site grading. They can catch and hold surface runoff before it leaves the site.
Divert upslope water around an area planned for disturbance.
Plan clearing and grubbing activities for a time of year that minimizes the impact of inclement weather on disturbed areas.
Temporarily stabilize or cover disturbed areas to minimize impacts on the environment.
Operators must only clear and grub acreage needed for activities occurring before the next anticipated storm event.
Clearing or grubbing too much land too early in construction dramatically increases the potential for surface water runoff and the costs to control it.
Operators must schedule grading to protect disturbed areas from stormwater runoff.
A minimum 100-foot buffer zone is required adjacent to perennial streams and water bodies in the State of Texas.
3.3.3 Stripping Activities
“Stripping” describes the removal of overburden on top of valuable sand reserves. Overburden is typically clay, silt, and fine sand. Operators may stockpile these materials for post-mining restoration. But the BMPs also allow disposal by placing them into a pit no longer being used.
Operators must control runoff from stockpiles.
Stockpiles should be located away from concentrated flows of storm water, drainage courses, and inlets, and protected with perimeter sediment barriers.
Operators should be able to effectively control runoff from any areas they disturb. So they should be careful not to strip too large of an area all at once. Stripping to large of an area contributes to excessive buildup of silt or clay in ditches.
Normally, operators will direct surface water to pits to keep the water table high in extended periods of dry weather.
Operators must leave enough undisturbed buffer at property boundaries to provide sufficient lateral support of property lines as determined by the licensed professional engineer or geoscientist certifying BMPs at the site.
Concerns
While I applaud what the TCEQ is trying to do, I still have concerns with several BMPs listed above and plan to make public comments on them.
Section 3.1 – Site Evaluation
This section requires a mine plan, but not approval of the plan. The plan should be approved by the TCEQ.
Most of the mines are at least partially in FEMA defined floodways. But this section makes no mention of that. Hydrologic and hydraulic analyses should be performed by competent and reputable third-party engineers to show that no part of the mine will increase flood levels or erosion upstream, downstream, or to adjoining properties.
FEMA Flood Map shows most Lake Houston Area sand mines are at least partially in floodways (cross-hatched areas).
Section 3.2.1 – Surface Water Flow
Additional erosion controls or increased buffer widths may be needed where river erosion rates are high,
Also, the East Fork, West Fork, Caney Creek, White Oak Creek, Spring Creek and Lake Houston already are listed as impaired. Impairments have to do mostly with bacteria, PCB, and/or dioxin levels. All of the above already have Total Maximum Daily Loads or are scheduled to implement TMDLs soon.
I suspect the TCEQ permits some discharges from sand mines and postpones others to keep the streams under the TMDL limit. But I have also seen many TCEQ reports about un-permitted discharges. I have seen breaches in dikes remain open for months and years. I have seen rivers capture pits during storms.
The West Fork already has a bacteria problem from the Lake Conroe Dam to Lake Houston. Yet people still swim and fish in these waters. And more sand mines are expanding than closing.
I wish the TCEQ would step up inspections (especially after heavy rains) and increase fines for un-permitted discharges. Lake Houston, after all, is the source of water for more than 2 million people.
Section 3.2.2 – Ground Water Conditions
This section requires operators to study the impact on adjacent water wells, but specifies nothing to reduce the impact on them. Ooops. I suggest adding: “If present, waste management units must be located a minimum horizontal distance from adjacent water wells, in accordance with 16 Texas Administrative Code Chapter 76.”
Section 3.3.2 – Land Clearing and Grubbing Activities
Diverting upslope water around a planned area for disturbance is good; however, care must be taken to prevent diverted water from increasing downslope flooding.
When the TCEQ says operators should clear and grub an amount of acreage that they can finish “before the next anticipated storm event,” it gives them an opportunity to clear hundreds of acres at once. Who can anticipate the next large rainfall in Houston? No one. Ask the people of Elm Grove how devastating sheet flow from a large area can be when a large rain hits before additional protections (i.e., detention ponds and berms) are installed.
Section 3.3.3 – Stripping Activities
The stockpile protection measures listed are good. But I would add that stockpiles must be located outside of FEMA-defined floodways.
This mine’s stockpile is located at the confluence of two floodways: for Caney and White Oak Creeks. Note the erosion after Imelda.Photo taken October 6, 2019.
Buffer widths between mines and adjoining properties are good. But I would add that “Additional buffer width or structures may be required where pipeline or utility corridors are located.
Please submit your thoughts on pre-mining and other BMPs to the TCEQ. Email Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
Posted by Bob Rehak on 8/14/2021
1446 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
https://i0.wp.com/reduceflooding.com/wp-content/uploads/2021/08/20191002-EF-WF-Aerial_601.jpg?fit=1200%2C800&ssl=18001200adminadmin2021-08-14 17:03:102021-08-14 17:33:27BMPs for Pre-Mining Phase of Sand Mining Can Help Prevent Erosion that Contributes to Flooding
At the very end of this post, I make some recommendations to strengthen BMPs, and describe how to submit public comments.
Structural Controls
Structural controls do several things:
Divert runoff away from disturbed areas
Reduce runoff velocities
Filter sediment
Remove sediment by ponding.
They include the following.
Temporary Structures (Section 2.2.1)
Installed before and during construction. After removing temporary stormwater controls the areas disturbed by the temporary structures must be revegetated.
Permanent Structures (Section 2.2.2)
Permanent structures remaining after construction. Once construction of areas outside of the sand-mining pit has ceased, permanent structural control BMPs must be implemented and operational.
Diversion Ridges, Berms or Channels of Stabilized Soil (Section 2.2.3)
These divert runoff into “sediment basins.” If they remain in place more than 30 days, they must be covered with temporary or permanent vegetation. Maximum allowable drainage area is five acres.
Silt Fences (Section 2.2.4)
Silt fences capture sediment from sheet flow. Six to eight inches of the fence material must be buried in a trench about four inches deep and four inches wide. Silt fences that are not buried have no useful function. They must never be installed across streams. Fencing must be removed when sediment deposits reach one-half the fence height.
Straw Bales (Section 2.2.4 Continued)
Can also be used as sediment barriers in small areas. Maximum grade: 3:1. Water depth must not exceed one foot at any point. Bales with bindings must be entrenched a minimum of four inches and anchored with stakes. Straw bales that are not buried are improperly installed.
Sediment Basins (Section 2.2.5)
Allow retention of sediment “prior to discharge” or recycling. Side slopes must be 2:1 or less.Sediment must be removed when the volume has been reduced to 27 cubic yards per acre of drainage area. Dikes must be well compacted and vegetated. Installed prior to construction but not in flowing streams. Use diversions to direct drainage to basins.
Riprap outlet protection must be placed at the outlet end of culverts or channels to reduce the depth, velocity, and energy of water so that the flow will not erode the receiving stream.
Check Dams (Section 2.2.7)
Small dams across swales or drainage ditches that reduce flow velocity and erosion. Not used in flowing streams. Maximum height: two feet. Center must be at least six inches lower than the outer edges to prevent erosion around the edges. The maximum spacing between dams must be such that the toe of the upstream dam is at the same elevation as the top of the downstream dam.
Accumulated sediment must be removed from behind the check dams when it reaches one half the dam height.Erosion around dam edges must be corrected immediately, ensuring that the dam center is six inches lower than the edges.
Construction Entrance/Exits (Section 2.2.8)
Aggregate must stabilize entrances and exits to reduce sediment tracked onto public roads. Aggregate must be at least six inches thick and 50 feet long. Tire washing may also be needed.
Housekeeping Practices (Section 2.2.9)
Petroleum products, paints, solvents, litter, debris, sanitary waste, and sediment from unstabilized areas, TCEQ BMPs specify:
Designated areas for equipment maintenance and repair;
Waste receptacles at convenient locations;
Regular collection of waste;
Protected storage areas for chemicals, paints, solvents, fertilizers, and other potentially toxic or hazardous materials; and
Control measures must be installed to control pollutants in stormwater after construction is complete. These controls include, but are not limited to:
Retention ponds. Minimum volume is the first inch or half inch of stormwater runoff containing the first flush of pollutants.
Vegetated Swales and Natural Depressions. There are grass-lined areas that filter sediments from runoff, thus helping to prevent erosion. Vegetated swales must have side slopes of 4:1 or less.
General
As with vegetative controls, operators must inspect structural controls once every seven (7) calendar days. That includes controls in areas used for storage of materials; maintenance areas; plus site entrances and exits.
Operators must replace or modify ineffective or damaged structural controls “in a timely manner, but no later than the next anticipated storm event.”
Recommendations for Public Comment Structural Controls
As we saw in yesterday’s post on vegetative controls, I have often seen gaps between real and ideal. However, for this post, I realized in looking back through thousands of aerial photos today, that I have never photographed one:
Stabilized channel
Silt fence
Straw bale
Check dam
Outlet stabilized by riprap or
Vegetated swale
…on a sand mine site. Period. Let alone one that met these requirements.
I’m not saying they don’t exist. I’m just saying that I’ve never seen them on the days I flew over.
Maybe operators feel they don’t need them. Or maybe they’re just not using them for other reasons.
So once again, I recommend that you write the TCEQ and ask them to put teeth into their BMP requirements.
In addition, I recommend you request:
Stronger wording on the general requirement to fix damaged or ineffective structural controls in a “timely manner.” That’s just too subjective. It lets operators defer maintenance way past the point it may be needed.
Clarification on “prior to discharging” in section 2.2.5. Are operators capturing sediment only to discharge it into the river at a later time? What do they mean by discharge? Where?
Detention ponds big enough to catch an inch of rain in an area where Atlas 14 requirements specify 16.9 inches of rain in 24 hours? (Section 2.2.10) That seems wholly inadequate. Harris County Flood Control District recommends minimum detention volumes for developments at .65 acre feet per acre for areas up to 640 acres. That’s about 8 inches of rainfall.
Please submit your thoughts on structural control and other BMPs to the TCEQ by emailing Macayla.Coleman@Tceq.Texas.gov with the subject line “BMPs Guidance Document” before August 19, 2021.
The house you save could be your own.
Posted by Bob Rehak on 8/13/2021
1445 Days since Hurricane Harvey
The thoughts expressed in this post represent opinions on matters of public concern and safety. They are protected by the First Amendment of the US Constitution and the Anti-SLAPP Statute of the Great State of Texas.
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